We’re working closely with the Office of Financial Sanctions Implementation (OFSI), UK law enforcement, and our regulatory partners to tackle the abuse of cryptoassets and associated money‑laundering activities. Read the full blog on the OFSI’s website.
Crypto ExchangeFintechPayment Provider We have signed a contract with Etrading Software (ETS) to deliver the UK bond consolidated tape. A high-quality tape will provide investors with a comprehensive overview of the bond market and support price formation and liquidity. It will help maintain the UK’s position as a highly competitive and compelling place to invest and grow.ETS has now launched a website that sets out key milestones and provides technical information for data contributors and users. We will continue to support ETS a...
Broker DealerAsset ManagerBank The latest Accelerated Settlement Taskforce (AST) report updates on the significant progress made towards the move to T+1. Read the AST report.Jamie Bell, head of capital markets at the FCA, said:'T+1 marks a major milestone in our drive to support growth and innovation. Faster settlement cycles will reduce risk, free up capital for faster reinvestment and align with other major markets.'We are delighted to see the great progress made last year highlighted in the AST’s report. By the end of t...
Broker DealerBankAsset Manager We have issued a joint statement with the Payment Systems Regulator (PSR) giving clarity on open banking pricing models. We and the PSR have issued the following statement (PDF).This confirms we will not, at this stage, prioritise a Competition Act 1998 (CA98) investigation into the centralised ‘access fee’ pricing model being developed by the UK Payments Initiative (UKPI) for commercial Variable Recurring Payments (cVRPs). cVRPs are an emerging open banking technology that allow consumers to...
The FCA and PSR have jointly confirmed they will not prioritize a Competition Act 1998 investigation into the UK Payments Initiative's (UKPI) centralized access fee pricing model for commercial Variable Recurring Payments (cVRPs), with the CMA's concurrent agreement. This regulatory clarity provides temporary certainty for cVRP development ahead of anticipated legislation by end-2026, creating a critical window for firms to develop compliant commercial models in this emerging open banking technology.
What Changed
The regulatory statement establishes the following key positions:
Non-prioritization of CA98 investigation: The FCA, PSR, and CMA have jointly confirmed they will not prioritize competition law enforcement against UKPI's centralized access fee model for Phase 1/Wave 1 cVRPs (limited to "lower risk" use cases).
Scope limitation: The regulatory clarity applies only to Phase 1/Wave 1 of UKPI's cVRP scheme, specifically addressing lower-risk payment use cases including regulated financial services
What You Need To Do
- *For UKPI and participating firms
- *Governance documentation
- *Pricing methodology transparency
- *Phase 1/Wave 1 compliance
- *Market engagement
Key Dates
15 January 2026 - FCA and PSR wrote to CMA setting out their non-prioritization position
16 January 2026 - CMA confirmed alignment with FCA/PSR position on CA98 prioritization
20 January 2026 - Joint FCA/PSR statement issued on open banking pricing models
Q1 2026 - Expected first live UKPI cVRP payments
End of 2026 - Government anticipated to introduce legislative framework granting FCA new open banking powers
Compliance Impact
Urgency: HIGH
The FCA and PSR have issued a joint statement providing clarity on open banking pricing models, specifically regarding the centralised 'access fee' pricing model for commercial Variable Recurring Payments (cVRPs). This statement confirms that they will not prioritize a Competition Act 1998 investigation into this model at this stage. The goal is to support the development of cVRPs, giving consumers more control over their payments and lowering processing fees for businesses.
What Changed
The FCA and PSR have clarified their enforcement position on the UKPI's proposal for a commercial model for cVRPs, indicating they will not prioritize a Competition Act 1998 investigation at this stage.
What You Need To Do
- Monitor market developments and updates on the legislative framework for open banking
- Review and understand the implications of the centralised 'access fee' pricing model for cVRPs on your business operations
- Ensure compliance with existing competition laws and regulations
Key Dates
31 Dec 2026 Expected implementation of the government's legislative framework for open banking DEADLINE
1 Jul 2027 End of the temporary measure if the legislative framework is not implemented DEADLINE
Non-Compliance Risk
Enforcement action, fines, or other regulatory penalties for non-compliance with competition laws and regulations
Related Regulations
Competition Act 1998Payment Services Directive (PSD2)
Confidence: high
BankFintechPayment Provider Policy statement 1/26
PS1/26 represents the UK Prudential Regulation Authority's final implementation framework for the Basel 3.1 international banking standards, effective 1 January 2027 (with market risk internal models delayed to 1 January 2028). This policy statement establishes mandatory capital, credit risk, operational risk, and market risk requirements for UK-regulated banks, building societies, and investment firms, addressing post-financial crisis shortcomings in risk-weighted asset (RWA) calculations and capital adequacy frameworks.
What Changed
*Credit Risk Framework**
Implementation of restrictions on Internal Ratings-Based (IRB) approach scope, effective 1 January 2027, with firms required to reclassify certain exposures (e.g., slotting approach IPRE exposures) as High-Volatility Commercial Real Estate (HVCRE) where applicable.
Minor clarifications and amendments to the Standardised Approach and credit risk mitigation techniques.
*Operational Risk**
Updated Business Indicator Component (BIC) calculation methodology requiring inclusi
What You Need To Do
- *Immediate (by mid-2026)
- *Conduct impact assessment
- *Review IRB permissions
- *Assess FRTB-IMA readiness
- *Arrange board-level assurance
Key Dates
20 January 2026 – PRA publishes PS1/26 (final rules)
1 January 2027 – Effective date for Basel 3.1 implementation (credit risk, operational risk, reporting/disclosure, IRB scope restrictions, SDDT regime)
1 January 2027 – Interim period begins for FRTB-IMA transition; existing IMA permissions retained; out-of-scope positions move to ASA/SSA
1 January 2028 – FRTB-IMA implementation effective date
2026 ICAAP submission deadline – Must include Basel 3.1/SDDT impact assessment DEADLINE
Compliance Impact
Urgency: HIGH
The Prudential Regulation Authority (PRA) has published the final rules for the implementation of Basel 3.1 standards in the UK, with an effective date of January 1, 2027. The rules aim to enhance the resilience of banks and improve the stability of the financial system. Firms must review and update their policies and procedures to ensure compliance with the new requirements.
What Changed
The PRA has introduced new rules for the calculation of risk-weighted assets, including changes to the credit risk standardised approach, market risk framework, and operational risk requirements. The rules also include amendments to the definitions of probability of default, loss given default, and conversion factor.
What You Need To Do
- Review and update credit risk policies and procedures to ensure compliance with the new standardised approach
- Assess the impact of the new market risk framework on trading book positions and capital requirements
- Update operational risk management frameworks to reflect changes to the Business Indicator and subcomponents
Key Dates
1 Jan 2027 Basel 3.1 rules take effect DEADLINE
1 Jan 2028 Internal model approach for market risk takes effect DEADLINE
Non-Compliance Risk
Non-compliance with the new rules may result in enforcement action, fines, or other regulatory penalties
Related Regulations
Basel 3.1Capital Requirements Regulation (CRR)Financial Services and Markets Act (FSMA) 2023
Confidence: high
BankBroker DealerAsset Manager
Policy statement 3/26
PS3/26 is the PRA's final policy statement restating the remaining provisions of the UK Capital Requirements Regulation (CRR) into the PRA Rulebook and related policy materials, effective 1 January 2027. This represents a critical step in the UK's transition away from assimilated EU law, consolidating fragmented regulatory requirements into a unified domestic framework while introducing targeted amendments to securitisation rules and External Credit Assessment Institution (ECAI) mapping.
What Changed
*Restatement of CRR Provisions**
The PRA is transferring remaining CRR requirements from the UK CRR into the PRA Rulebook without material changes to policy substance, except for targeted securitisation amendments. This follows the earlier PS12/25, which finalised the first tranche of restatement requirements in 2026.
*Policy Materials and Supervisory Guidance
PS3/26 introduces or amends multiple supervisory statements and statements of policy:
New: SS4/24 (Credit risk: Internal Ratings Based A
What You Need To Do
- *Immediate (by Q2 2026)
- *Review applicability
- *Assess impact
- *Identify policy changes
- *Medium-term (by Q3 2026)
Key Dates
20 January 2026 - PS3/26 final policy statement published
28 October 2025 - PS19/25 (near-final policy) published
1 January 2027 - All policies take effect; HM Treasury commencement regulations revoke relevant CRR provisions and replace them with PRA Rulebook rules and policy materials
Compliance Impact
Urgency: HIGH
The Prudential Regulation Authority (PRA) has published a policy statement (PS3/26) that restates the remaining relevant provisions in the Capital Requirements Regulation (CRR) within the PRA Rulebook and other policy materials. This change aims to ensure that the PRA's rules and policies are consistent with the UK's withdrawal from the EU. The policy statement is relevant to PRA-authorised banks, building societies, and other financial institutions.
What Changed
The PRA has restated the remaining relevant provisions in the CRR within the PRA Rulebook and other policy materials, including amendments to supervisory statements and the introduction of new statements of policy. The changes include updates to the securitisation requirements and the introduction of new rules on credit risk and internal ratings-based approaches.
What You Need To Do
- Review and update internal policies and procedures to ensure compliance with the restated CRR provisions
- Ensure that risk management practices are aligned with the updated rules on credit risk and internal ratings-based approaches
- Review and update securitisation policies and procedures to ensure compliance with the amended requirements
Key Dates
1 Jan 2027 The restated CRR provisions take effect DEADLINE
Non-Compliance Risk
Failure to comply with the restated CRR provisions may result in enforcement action, fines, or other regulatory penalties
Related Regulations
Capital Requirements Regulation (CRR)Basel 3.1Solvency II
Confidence: high
BankBroker DealerAsset Manager
Policy statement 4/26
PS4/26 finalizes the **simplified capital regime for Small Domestic Deposit Takers (SDDTs)**, a tailored prudential framework designed to reduce regulatory burden while maintaining capital resilience for smaller, domestically-focused UK banks and building societies. This represents the completion of Phase 1 of the PRA's "Strong and Simple" initiative and introduces materially lighter capital, liquidity, and reporting requirements for qualifying firms, with implementation effective January 1, 2027.
What Changed
*Simplified Capital Framework
The final policy introduces a dedicated capital regime** for SDDTs that descopes them from standard CRR Firms requirements. SDDTs are now subject to tailored Pillar 2 methodologies (SoP5/25) and simplified ICAAP/SREP processes (SS4/25) rather than the standard frameworks.
*Liquidity Simplifications
Qualifying SDDTs with 50% or more retail deposit funding** are exempted from the Net Stable Funding Ratio (NSFR) requirements, replacing this with a simpler Retail Depos
What You Need To Do
- *Immediate (by January 20, 2026)
- *Assess SDDT eligibility – Determine whether your firm meets all seven qualification criteria, particularly the £20bn asset threshold and domestic asset location requirement
- *Review consolidation group structure – If part of a group, confirm which entity will serve as the SDDT consolidation entity responsible for certification
- *Implement SoP2/23 changes – Adopt updated operating procedures for the SDDT regime
- *Update ICAAP/ILAAP processes – Implement new frequency requirements for capital and liquidity adequacy assessments
Key Dates
January 20, 2026 – PS4/26 published; changes to SoP2/23 and ICAAP/ILAAP frequency requirements take effect
January 20, 2026 – Revocation of ICR firm/consolidation entity definitions and deletion of SoP3/23 effective
January 1, 2027 – Simplified capital regime for SDDTs takes effect; SS4/25 brought into effect in full; SDDTs removed from SS31/15 scope
Compliance Impact
Urgency: HIGH
The Prudential Regulation Authority (PRA) has introduced a simplified capital regime for Small Domestic Deposit Takers (SDDTs) to reduce regulatory complexity while maintaining adequate capital. The new regime will take effect on 2027-01-01. This change aims to simplify capital requirements for smaller banks and building societies.
What Changed
The PRA has introduced a new simplified capital regime for SDDTs, which includes changes to the PRA Rulebook, supervisory statements, and statements of policy. The regime also introduces new reporting templates and instructions.
What You Need To Do
- Review and update capital adequacy assessments to ensure compliance with the new simplified capital regime
- Implement new reporting templates and instructions for SDDTs
- Update internal policies and procedures to reflect changes to the PRA Rulebook, supervisory statements, and statements of policy
Key Dates
20 Jan 2026 Publication of the final policy statement
20 Jan 2026 Early implementation of changes to ICAAP updates and reverse stress-testing
1 Jan 2027 The SDDT capital regime takes effect DEADLINE
Non-Compliance Risk
Enforcement action, fines, or license revocation for non-compliance with the new simplified capital regime
Related Regulations
CRRBasel 3.1
Confidence: high
Bank
The FCA, Bank of England and Prudential Regulation Authority have together signed a Memorandum of Understanding (MoU) with the European Supervisory Authorities to enhance cooperation and oversight of critical third parties (CTPs) that fall under the UK’s CTP regime.The MoU establishes a framework for coordinating and sharing information on the oversight of CTPs under the UK regime and critical third party providers (CTPPs) under the EU’s Digital Operational Resilience Act (DORA), including du...
The FCA, Bank of England (BoE), and Prudential Regulation Authority (PRA) have signed a Memorandum of Understanding (MoU) with the European Supervisory Authorities (ESAs) to coordinate oversight of critical third parties (CTPs) under the UK's CTP regime and critical third party providers (CTPPs) under the EU's Digital Operational Resilience Act (DORA). This matters because it enhances cross-border information sharing and cooperation during incidents like cyber-attacks, reducing regulatory duplication while bolstering financial stability and operational resilience for firms reliant on these providers.
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What Changed
Establishes a framework for timely information sharing, coordination of oversight activities, and joint responses to incidents affecting CTPs/CTPPs, including power outages or cyber-attacks.
Defines principles for cooperation on mutually designated CTPs/CTPPs, including notifications of investigations and best endeavors to share material information where legally and operationally feasible.
Complements the UK's CTP regime (effective 1 January 2025), which requires designated CTPs to provide regu
What You Need To Do
- For CTPs/CTPPs
- For financial firms/FMIs
- Regulators' internal actions
- Firms should review contracts with third parties for compliance alignment and conduct gap analyses against CTP requirements
Key Dates
1 January 2025 UK CTP rules came into effect, applying to CTPs designated by HMT.
Ongoing (process begun pre-2025) HMT designation process for CTPs, with regulators recommending based on concentration and materiality criteria; no fixed end date specified.
DORA effective date (prior context) EU CTPPs oversight under DORA aligns with UK regime; MoU signed to ensure compatibility (exact DORA timeline not in publication but supports post-2024 implementation).
Compliance Impact
Urgency: High – The MoU operationalizes the live UK CTP regime (effective January 2025), with designations underway, amplifying risks of non-compliance for firms using critical ICT providers amid rising cyber and resilience threats. It matters for cross-border firms as it enables regulator-to-regula
BankPayment ProviderAll Firms
A growing number of investment schemes are being promoted unlawfully, are high risk and may even be scams. We've identified a growing number of investment schemes in holiday lodges and holiday homes being promoted to UK consumers by companies that are not FCA authorised.They may be unregulated collective investment schemes, where several investors invest their money. The schemes are being promoted unlawfully, are high risk and may even be scams. We remind consumers that if you invest in an un...
The FCA has issued a consumer warning about unregulated investment schemes in holiday lodges and holiday homes, which are often promoted unlawfully by unauthorised firms, posing high risks or outright scams. These schemes typically involve collective investments without FCA authorisation, breaching UK financial promotion and collective investment scheme (CIS) rules. This matters for compliance professionals as it signals heightened FCA scrutiny on unauthorised promotions, potential enforcement actions, and the need for firms to review marketing materials and client referrals to avoid facilitation risks.
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What Changed
This is not a formal rulemaking or policy change but a consumer alert and enforcement signal under existing regulations. Key reminders include:
Unauthorised firms cannot lawfully promote collective investment schemes (CIS) under section 21 of the Financial Services and Markets Act 2000 (FSMA).
Holiday park schemes pooling investor funds for lodge purchases and management often qualify as unregulated CIS, making promotions illegal.
No new requirements are introduced, but the FCA emphasises its on
What You Need To Do
- Immediate verification
- Client communication review
- Training and monitoring
- Internal reporting
- Due diligence
Compliance Impact
Urgency: High. This alert indicates active FCA enforcement priority on consumer-facing scams in property-linked investments, with risks of fines, bans, or asset freezes for non-compliance (e.g., similar to past actions against mini-bond issuers). Firms face heightened supervisory visits or thematic
Wealth ManagerAsset ManagerAll Firms
We confirm that the FCA has opened an investigation into WH Smith PLC. The investigation concerns potential breaches of UK Listing Principles and Rules and Disclosure and Transparency Rules in relation to the matters announced by WH Smith PLC on 19 November 2025.
The FCA has launched an investigation into WH Smith PLC for potential breaches of UK Listing Principles and Rules, as well as Disclosure and Transparency Rules (DTRs), stemming from announcements made by the company on 19 November 2025. This underscores the FCA's heightened scrutiny of listed companies' disclosure practices and adherence to market conduct standards. Compliance professionals should note this as a signal of enforcement risk in timely and accurate market disclosures, potentially setting precedents for similar cases.
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What Changed
This is not a policy change or new rule; it is an enforcement investigation announcement with no immediate regulatory amendments. It highlights ongoing enforcement of existing rules:
UK Listing Principles and Rules: These require listed issuers to act with integrity, provide accurate and timely information, and maintain effective systems for compliance (e.g., Principle 2 on communication with investors; Listing Rule 9 on continuing obligations).
Disclosure and Transparency Rules (DTRs): Specific
What You Need To Do
- For WH Smith PLC
- For other listed firms
- announcement sign-off processes involving legal/compliance/IR
- plan profit warnings or material updates, documenting decision trails
Key Dates
19 November 2025 - WH Smith PLC announcement triggering the investigation (reference point for alleged breaches).
late 2026 or 2027. Firms should monitor FCA updates via the specific URL or FCA enforcement news.
Compliance Impact
Urgency: High. This matters due to the FCA's aggressive enforcement posture on market abuse/disclosures (e.g., post-SPPF reforms emphasizing individual accountability). Breaches can lead to multimillion-pound fines (e.g., 10% of annual revenue), director bans, and reputational damage, amplified by p
All Firms
No description available.
The CFTC approved a final rule on December 18, 2025, that codifies existing staff no-action positions and eliminates duplicative business conduct and documentation requirements for swap dealers and major swap participants. This rule resolves over a decade of regulatory uncertainty, reduces operational costs, and harmonizes CFTC requirements with SEC and Municipal Securities Rulemaking Board standards.
What Changed
The final rule introduces the following substantive amendments:
*Exceptions for Swaps Intended to be Cleared (ITBC Swaps)**
Swap dealers and major swap participants are exempted from certain External Business Conduct Standards and swap trading relationship documentation requirements when executing swaps that are intended by the parties to be cleared contemporaneously with execution. Such swaps are deemed void if rejected from clearing.
*Prime Broker Arrangement Exemptions**
Swaps executed purs
What You Need To Do
- *Immediate Actions (Pre-Implementation)
- *Implementation Actions (Upon Effective Date)
- trade disclosure systems to remove PTMMM generation and delivery requirements
- based operations, review implications of superseded Staff Letter No
- *Ongoing Compliance
Key Dates
April 4, 2025 - CFTC Staff Letter 25-09 issued, establishing no-action position on PTMMM requirement
September 12, 2025 - CFTC issued further amended exemptive order permitting JSCC to clear interest rate swaps
September 24, 2025 - CFTC issued Notice of Proposed Rulemaking (comment period opened)
October 24, 2025 - Comment period deadline (ISDA and SIFMA submitted comments on this date) DEADLINE
December 18, 2025 - CFTC approved final rule (subject to pre-publication technical corrections)
Compliance Impact
Urgency: HIGH
Broker DealerBank
We're expanding the significant work we had planned to improve standards in the home and travel insurance markets, following Which?’s super complaint. Read our response to Which? (PDF)While 79% of consumers who make an insurance claim are satisfied with how it was handled, our work shows there's room for improvement - with 3 in 10 (31%) saying there isn’t enough information to judge the quality of different policies. Over the next year, we will do more to: Improve claims handling, by reviewin...
The FCA is expanding its planned supervisory work in home and travel insurance markets in response to a Which? super complaint, focusing on improving claims handling, information provision, and overall standards. This matters for compliance professionals as it intensifies scrutiny under Consumer Duty, requiring firms to demonstrate better consumer outcomes amid ongoing simplification of insurance rules. It signals heightened FCA expectations for evidence-based improvements in customer satisfaction and transparency.
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What Changed
This statement announces an expansion of existing planned work rather than new rules, with specific emphases over the next year on:
Improving claims handling through reviews of firms' processes.
Enhancing information available to consumers for judging policy quality (addressing the 31% dissatisfaction rate).
Building on prior simplification efforts, such as risk-based product reviews (replacing annual mandates), removal of prescriptive CPD requirements (e.g., 15 hours), and reduced data returns,
What You Need To Do
- Review and enhance claims handling processes to ensure efficiency and fairness, preparing evidence for FCA supervisory reviews
- Improve pre-sale information on policy quality, addressing gaps where 31% of consumers lack sufficient data
- Adopt risk-based product and distribution reviews (per PS25/21), documenting rationale for frequency based on harm risks; align with co-manufacturers
- Embed Consumer Duty via outcomes monitoring, data-driven MI on customer behavior/complaints, and vulnerability support; shift from process compliance to evidenced effectiveness
- Retain records, respond to FCA data requests, and invest in governance/MI for supervision
Key Dates
Over the next year (from publication, approx. late 2025) - FCA to conduct expanded reviews on claims handling, information provision, and standards improvement.
2026 - FCA to decide on changes to GAP insurance product-specific rules.
Q2 2026 - FCA consultation on removing non-UK customers from Consumer Duty scope, with parallel review of ICOBS and PROD application.
H1 2026 - FCA consultations on Consumer Duty amendments for distribution chains and UK customer focus.
September 2026 - Conduct Rules (COCON) expand to non-financial misconduct.
Compliance Impact
Urgency: High - This expands active FCA supervision in 2026, overlapping with Consumer Duty embedding and insurance simplification; non-compliance risks intensified reviews, enforcement, or redress schemes (as seen in motor finance). Firms gain flexibility but face accountability for outcomes, with
Insurance
The FCA welcomes the Government’s consultation on a new benchmarks regime for the UK. Since the introduction of the current regulatory framework, the financial landscape has evolved significantly. We now have an opportunity to build a regime that is more targeted to current market conditions and to reduce unnecessary burdens on industry, without compromising high standards. We are working with the Government to reform the current benchmarks regime to ensure that the regulatory framework remai...
The FCA welcomes HM Treasury's consultation on reforming the UK Benchmarks Regulation (BMR) to create a narrower, risk-based **Specified Authorised Benchmarks Regime (SABR)**, reducing regulatory scope by 80-90% to target only systemically important benchmarks and administrators while easing burdens on industry. This matters for compliance professionals as it shifts from broad regulation of all benchmarks to targeted oversight, requiring firms to reassess benchmark usage, prepare for transition, and adapt to FCA rules on risk management, enhancing UK competitiveness post-FSMA 2023 repeal of assimilated laws.
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What Changed
Narrower scope: Regulation limited to benchmarks/administrators designated by HM Treasury (HMT) on FCA advice, based on criteria like systemic impact on UK financial integrity, consumers, or markets; reduces coverage by 80-90%, with no distinction between critical/significant/other types or benchmark categories (e.g., interest rate, commodity).
FCA-led firm-facing rules: HMT delegates requirements (governance, conflicts, oversight, methodology transparency, record-keeping) to FCA Handbook; remov
What You Need To Do
- Review current benchmarks for potential designation risk (systemic impact criteria) and map usage across portfolios
- Participate in HMT consultation (responses via gov
- Develop/revise policies for benchmark risk management, including cessation/wind-down plans for regulated/non-regulated benchmarks per future FCA guidance
- Assess transition from current authorisation (if non-designated, prepare for deregistration); overseas firms evaluate ORR eligibility
- Update governance/conflicts frameworks for any designated activities; monitor ESG data inclusion in rules
Key Dates
17 December 2025 - HM Treasury publishes consultation on benchmarks regime reform.
1 January 2026 - Reforms take initial effect; UK becomes only jurisdiction regulating all local benchmarks pre-reform; EU BMR reforms effective, highlighting UK divergence.
Due course 2026 - FCA consults on regulatory requirements for designated administrators/users.
2026 - FCA expected to publish updated guidance on critical benchmarks and implement SABR refinements.
Compliance Impact
Urgency: High - Significant scope reduction eases burdens but introduces transition risks, new FCA rules, and designation uncertainty; firms must act now on consultation (post-Dec 2025) and prep for 2026 FCA changes to avoid non-compliance during shift, especially with 1 Jan 2026 milestone amplifyin
Asset ManagerBankBroker Dealer An update on our investigation into Mirabella Advisors LLP. On 4 May 2021, we announced that we had opened an investigation into the oversight of Greensill Capital Securities Limited, an appointed representative, by its principal, Mirabella Advisors LLP. Our investigation reviewed the nature, conduct and scope of Mirabella’s business. We did not identify breaches by Mirabella that require further action. The investigation has therefore now closed. Mirabella applied to have its authorisation c...
The FCA has closed its investigation into Mirabella Advisors LLP's oversight of its appointed representative (AR), Greensill Capital Securities Limited, finding no breaches warranting further action. This closure, announced after reviewing Mirabella's business nature, conduct, and scope, signals effective AR oversight in this high-profile case tied to the Greensill collapse, while Mirabella voluntarily cancelled its authorisation effective 12 September 2025. It matters for compliance professionals as it reinforces FCA expectations on principal-AR relationships without imposing new penalties or rules, but underscores ongoing scrutiny in trade finance and supply chain finance sectors.
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What Changed
There are no new regulatory changes, requirements, or rules introduced by this publication. The statement solely announces the closure of an existing investigation with no identified breaches by Mirabella, maintaining the status quo on AR oversight obligations under FCA rules such as SUP 12 (Appointed Representatives). The FCA reserves the right to reopen if new information emerges, but no policy shifts or guidance updates are provided.
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Key Dates
4 May 2021 - FCA announced opening of investigation into Mirabella's oversight of Greensill Capital Securities Limited as AR.
12 September 2025 - Mirabella's authorisation cancelled; firm no longer provides financial services.
Compliance Impact
Urgency: Low - This is a positive closure with no findings of misconduct, new rules, or enforcement, reducing immediate compliance burdens. It matters indirectly by exemplifying robust AR oversight meeting FCA standards amid Greensill fallout, offering reassurance for similar firms while signaling c
Asset ManagerBroker DealerAll Firms
Policy statement 27/25
PS27/25 finalizes the PRA's policy to delete 37 redundant banking regulatory reporting templates (34 FINREP, 2 COREP, and PRA109) as the first phase of the Future Banking Data (FBD) programme, aiming to reduce reporting burdens while maintaining supervisory data quality. This matters for PRA-regulated banks as it delivers immediate cost savings and signals broader regulatory simplification, aligning with the PRA's secondary competitiveness and growth objective.
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What Changed
Deletion of 37 whole reporting templates identified as duplicative, outdated, or low-value: 34 FINREP templates, 2 COREP templates (C05.01 and C05.02, now obsolete), and PRA109.
Consolidation of remaining FINREP scoping provisions into a single section of the PRA Rulebook (new Chapters 5A–5F of the Reporting (CRR) Part), with clarifications to unclear or duplicative conditions.
Alignment of FINREP remittance deadlines to 30 business days for reports under Article 430(3), Article 11(2), and new C
What You Need To Do
- Review and update internal reporting systems, processes, and controls to cease submission of the 37 deleted templates for reference dates from 31 December 2025 onwards
- Confirm applicability of consolidated FINREP scoping rules (Chapters 5A–5F) and adjust scoping for remaining templates, incorporating clarified conditions
- Assess eligibility for individual FINREP waivers under the updated framework if part of a UK consolidation group; apply to PRA if criteria met (90-95% asset contribution)
- Update compliance policies and training to reflect SS34/15 amendments and aligned remittance deadlines
- Review Pillar 3 disclosure obligations for any ongoing requirements tied to deleted templates and prepare for potential future changes
Key Dates
8 December 2025 - Publication of PS27/25, finalizing policy and responses to CP21/25 consultation.
31 December 2025 - Effective date for revised rules, amended SS34/15, and deletions; applies to reporting reference dates falling on or after this date (avoids 2025 Q4 submissions where relevant).
11 November 2025 - Q3 2025 remittance deadline (precedes PS publication, so no concession for early non-reporting). DEADLINE
Compliance Impact
Urgency: Medium – Changes are simplificatory (deletions reduce burden), with immediate effect from 31 December 2025, but no new requirements or penalties for non-compliance with deleted items; firms must act promptly to decommission processes and avoid erroneous submissions. This matters as it lower
Bank
Policy statement 26/25
The Prudential Regulation Authority (PRA) has issued PS26/25, finalizing the withdrawal of Supervisory Statement (SS) 20/15, which previously set prescriptive expectations for building societies' treasury and lending activities, effective immediately upon publication on 5 December 2025. This deregulatory move reduces administrative burdens, enhances proportionality across deposit takers, and promotes competition by aligning building societies more closely with banks, while relying on existing tools like the PRA Rulebook, SMCR, and routine supervision for risk management. It matters for compliance teams as it eliminates specific guidance often misinterpreted as binding requirements, freeing firms to tailor risk frameworks but requiring vigilance on broader prudential expectations.
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What Changed
Full deletion of SS20/15: Removes all expectations on treasury and lending activities, including the "Treasury Approaches" framework, without replacement.
Consequential amendments: Updates SS31/15 (Internal Capital Adequacy Assessment Process and Supervisory Review and Evaluation Process) to excise references to SS20/15.
Alignment with broader policy: Addresses inconsistencies with PRA's approach for banks, improved sector risk management maturity, and proportionality for smaller firms; supports
What You Need To Do
- Review and update policies
- Assess risk management
- Update governance documents
- Engage supervisors
- Monitor related reforms
Compliance Impact
Urgency: Medium – Effective immediately (5 December 2025), but deregulatory nature reduces burdens rather than imposing new obligations; critical for year-end 2025/early 2026 planning to avoid legacy SS20/15 misapplication. Matters as it shifts from prescriptive "hard limits" (often treated as rules
Bank
Policy statement 25/25
PS25/25 is the PRA's policy statement providing feedback on CP10/25 and issuing updated Supervisory Statement SS5/25, which replaces SS3/19 to enhance banks' and insurers' management of climate-related financial risks through strengthened governance, risk management, scenario analysis, data quality, and disclosures. It matters because it sets a higher regulatory bar for embedding climate risks proportionately into core processes like ICAAP, ILAAP, ORSA, and financial reporting, promoting resilience and strategic decision-making amid evolving climate threats.
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What Changed
The main changes in SS5/25 from SS3/19 and CP10/25 responses include:
Proportionate application clarification: New 'Overarching aims' section in Chapter 3 explains how firms should tailor expectations to their climate risk exposure, business size, and complexity via a two-step process (assess materiality, then respond).
Governance strengthening: Boards and senior management must actively oversee climate risks, embedding them in strategy and ensuring accountability.
Risk management enhancements:
What You Need To Do
- Conduct gap analysis against SS5/25 within 6 months and remediate (e
- Integrate climate risks into board oversight, strategy, risk registers, ICAAP/ILAAP (banks), ORSA/stress testing (insurers), and financial reporting
- Perform CSA exercises commensurate with exposures, using suitable scenarios to inform decisions; enhance data quality and disclosures
- Document proportionate application (two-step process: materiality assessment, risk response); leverage existing structures where robust
- Ensure senior accountability and alignment with standards like SS1/21
Key Dates
3 December 2025 - PS25/25 and SS5/25 published; SS5/25 effective immediately, replacing SS3/19.
Within 6 months (by ~June 2026) - Firms assess gaps against new expectations and develop remediation plans (industry guidance).
Ongoing - Forward-looking, strategic implementation proportionate to risks; PRA may request progress evidence.
Compliance Impact
Urgency: High – Effective immediately (3 Dec 2025), requiring significant uplift to existing approaches; non-compliance risks supervisory scrutiny, as PRA expects ambitious, ongoing progress and may request evidence. Matters for capital/liquidity planning, resilience, and strategic viability amid ma
BankInsurance
Policy statement 23/25
PS23/25 from the PRA and FCA finalizes amendments to Binding Technical Standards (BTS) 2016/2251 under UK EMIR, introducing an indefinite exemption for single-stock equity options and index options from bilateral margin requirements, removing IM obligations on legacy contracts for firms falling below thresholds, and allowing alignment with third-country jurisdictions' timelines for IM assessments. These changes reduce operational burdens and enhance competitiveness for UK firms trading non-centrally cleared derivatives, following feedback from CP5/25, while maintaining prudential standards.
#
What Changed
Indefinite exemption for equity options: Single-stock equity options and index options are permanently exempted from UK bilateral initial margin (IM) and variation margin (VM) requirements, replacing a temporary exemption ending 4 January 2026. This balances safety with international competitiveness, as capital can substitute for margin.
Legacy contracts relief: Firms falling below the Average Aggregate Notional Amount (AANA) threshold no longer need to exchange IM on outstanding legacy non-cent
What You Need To Do
- Assess cross-border transactions
- Conduct gap analysis on margin calculations, collateral management, and reporting; train front-to-back office teams on changes
- Retain records of AANA calculations and threshold monitoring to justify exemptions or relief
- For firms with collected IM on now-exempt legacy positions, evaluate release options per updated FCA instrument language
Key Dates
11 August 2025 PRA submits final technical standards instrument to HM Treasury (HMT).
15 August 2025 FCA submits final technical standards instrument to HMT.
11 September 2025 HMT deems approval of PRA’s instrument.
24 September 2025 HMT deems approval of FCA’s instrument.
27 November 2025 Amendments to BTS 2016/2251 effective date.
Compliance Impact
Urgency: High – Effective immediately since 27 November 2025 (over a month ago as of current date), firms risk non-compliance if systems still enforce outdated IM/VM for exemptions; operational fixes are needed urgently to avoid breaches, fines, or disputes, especially with phase-out of temporary eq
BankBroker DealerAsset Manager
Policy statement 24/25
The PRA's PS24/25 finalizes rules increasing Financial Services Compensation Scheme (FSCS) depositor protection limits from £85,000 to £120,000 and temporary high balances (THB) from £1 million to £1.4 million for firm failures on or after 1 December 2025, responding to consultation feedback in CP4/25. This matters for PRA-authorized deposit-takers as it enhances consumer protection amid inflation but requires urgent system and disclosure updates to avoid FSCS payout delays or regulatory breaches. Firms must prioritize single customer view (SCV) readiness and phased disclosure revisions to comply efficiently.
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What Changed
Increased Protection Limits: Standard FSCS deposit limit rises from £85,000 to £120,000; THB limit from £1 million to £1.4 million, applying to failures from 1 December 2025.
SCV System Updates: Firms must update SCV systems (used by FSCS for rapid compensation) to reflect new limits from 1 December 2025, including accurate contact details.
Disclosure Materials:
- Update information sheets on FSCS cover to reflect new limits and improve clarity/accessibility; provide to depositors as soon as
What You Need To Do
- Immediate (pre-1 Dec 2025)
- By 1 Dec 2025
- Post-1 Dec 2025 to 31 May 2026
- Document changes for audit trails; consider regtech for SCV automation
Key Dates
1 December 2025 - New deposit (£120,000) and THB (£1.4 million) limits apply to firm failures on/after this date; SCV systems must be updated; SS18/15 and SoP1/15 effective. DEADLINE
As soon as practicable after 1 December 2025 - Provide updated information sheets, stickers/posters, and exclusions lists to depositors (encouraged immediately to avoid confusion).
31 May 2026 - Firm deadline for all disclosure material updates and provision to depositors (six-month transition ends). DEADLINE
Compliance Impact
Urgency: High – SCV updates are mandatory by 1 December 2025 with no transition, risking delayed FSCS payouts and enforcement if unprepared; disclosure changes allow six months but PRA emphasizes early action to prevent depositor confusion. Impacts operational resilience and conduct risk; non-compli
Bank
Policy statement 22/25
The PRA's PS22/25 finalizes an increase in the retail deposits threshold for the leverage ratio requirement from £50 billion to £75 billion, introducing a three-year averaging mechanism for calculations, effective 1 January 2026. This adjustment reflects nominal UK GDP growth since 2016 to maintain the Financial Policy Committee's original risk appetite while smoothing cliff-edge effects for firms like building societies. It matters for major UK banks and similar firms as it alters capital planning and leverage ratio applicability, potentially reducing immediate compliance burdens for those nearing the old threshold.
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What Changed
Retail deposits threshold raised from £50 billion to £75 billion, adjusted upward from the CP2/25 proposal of £70 billion to account for further GDP growth to Q2 2025 (rounded to nearest £5 billion).
Introduction of a three-year moving average for calculating retail deposits metric, replacing point-in-time values to mitigate volatility and aid capital planning, particularly for building societies.
Non-UK assets threshold remains unchanged at £10 billion.
Modifications by consent disapplying leve
What You Need To Do
- Review and update internal retail deposits calculations to incorporate three-year moving average methodology starting 1 January 2026
- Assess current and projected retail deposits against £75 billion threshold (and £10 billion non-UK assets) to determine leverage ratio applicability and adjust capital planning accordingly
- Prepare to meet 3
- For firms with modifications by consent
- Update governance, risk models, and board reporting to reflect changes; conduct gap analysis against PRA Rulebook appendices in PS22/25
Key Dates
5 March 2025 - PRA publishes Consultation Paper CP2/25 proposing £70 billion threshold.
5 June 2025 - Consultation response deadline. DEADLINE
12 November 2025 - PRA issues PS22/25 with final policy.
1 January 2026 - Final policy takes effect, applying new £75 billion threshold and three-year averaging.
30 June 2026 - Cessation of modifications by consent disapplying leverage ratio rules.
Compliance Impact
Urgency: High – With effectiveness just after today (1 January 2026), firms near £50-75 billion in retail deposits face immediate recalibration of leverage exposures and capital buffers to avoid breaches, amplified by the shift to averaging which requires historical data reconstruction. Non-complian
BankPayment ProviderAll Firms
The Financial Policy Committee (FPC) welcomes today the Prudential Regulation Authority’s (PRA’s) policy statement 20/25 – The Strong and Simple Framework: The simplified capital regime for Small Domestic Deposit Takers (SDDTs) – near-final.
The Financial Policy Committee (FPC) welcomes the Prudential Regulation Authority's (PRA) Policy Statement (PS) 20/25, which finalizes the second phase of the "Strong and Simple Framework" by introducing a simplified capital regime for Small Domestic Deposit Takers (SDDTs), alongside liquidity simplifications. This matters because it reduces regulatory burdens, enhances competition among smaller UK banks and building societies, and maintains resilience without full Basel 3.1 standards, with implementation on 1 January 2027.
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What Changed
Pillar 1 simplifications: Adoption of Basel 3.1 standardised approaches to credit and operational risk; disapplication of due diligence for credit risk, simplifications to market risk, removal of counterparty credit risk and CVA requirements for derivatives (with exceptions), and adjustments to Leverage Ratio and Large Exposures.
Pillar 2A methodologies: Simplifications for credit risk, credit concentration risk (CCoR), and operational risk; amendments to single-name concentration monitoring (cl
What You Need To Do
- Assess SDDT eligibility
- Update capital frameworks
- ICR transitions
- Policy and process revisions
- Supervisory engagement
Key Dates
17 January 2025 Deadline for comments on related CP14/24. DEADLINE
28 October 2025 Publication of near-final PS20/25.
1 January 2026 Full Basel 3.1 standards apply to ICR opt-in firms (ICR revoked); some changes to SoP2/23, ICAAP/ILAAP update frequencies effective from PS4/26 publication.
20 January 2026 Publication of final PS4/26 confirming PS20/25; effective date for ICAAP/ILAAP updates (including reverse stress-testing).
1 January 2027 Simplified capital regime for SDDTs takes full effect.
Compliance Impact
Urgency: High – With full implementation on 1 January 2027 (less than 12 months from today), SDDTs face tight timelines for capital recalibrations, ICR exits, and reporting overhauls; missing deadlines risks supervisory intervention or full Basel 3.1 compliance costs. This significantly eases burden
BankFintech
Policy statement 19/25
**PS19/25** is the PRA's near-final policy statement finalizing how remaining Capital Requirements Regulation (CRR) provisions will be restated into the PRA Rulebook, effective January 1, 2027. This represents a critical step in the UK's transition away from assimilated EU law, giving the PRA expanded rule-making authority over UK banks, building societies, and investment firms while introducing targeted policy changes to securitisation, credit risk treatment, and ECAI mapping.
What Changed
The near-final policy confirms and finalizes the following substantive amendments:
*Securitisation Requirements**
Largely preserves current requirements and supervisory expectations with targeted policy changes
Introduces a new formulaic p-factor for the standardised approach to securitisation
Establishes new capital rules for certain mortgage exposures
Clarifies supervisory expectations for unfunded credit protection in synthetic Significant Risk Transfer (SRT) securitisations by adding expect
What You Need To Do
- *Review the final policy statement when published in Q1 2026 to understand specific rule changes applicable to your firm's business model
- *Assess securitisation impacts
- *Evaluate mortgage capital treatment
- *Update ECAI mapping processes
- *Establish implementation timeline
Key Dates
28 October 2025 - PRA published near-final policy statement PS19/25
Q1 2026 - PRA intends to publish final policies and rule instruments alongside or shortly after final Basel 3.1 package publication
1 January 2026 - Implementation date for certain proposals finalized in PS12/25 (limited scope)
1 January 2027 - Implementation date for policies and requirements in PS19/25 (primary implementation date)
Compliance Impact
Urgency: HIGH
BankBroker Dealer
Policy Statement 20/25
**PS20/25** represents the second and final phase of the PRA's "Strong and Simple Framework," establishing a significantly simplified capital regime for Small Domestic Deposit Takers (SDDTs) while maintaining their resilience. This near-final policy statement, published on 28 October 2025, fundamentally restructures capital requirements, liquidity rules, and operational frameworks for SDDTs—a critical development for smaller deposit-taking institutions seeking regulatory relief from disproportionate compliance burdens.
What Changed
The simplified capital regime introduces structural changes across all three pillars of capital requirements:
*Pillar 1 (Risk-Weighted Assets)
SDDTs must apply Basel 3.1 standardised approaches for credit risk and operational risk, with specific simplifications.
Due diligence requirements in the standardised approach to credit risk are disapplied for SDDTs.
Counterparty credit risk (CCR) for derivatives and credit valuation adjustment (CVA) risk are disapplied (with minor exceptions).
Market ri
What You Need To Do
- *For SDDTs Currently Operating or Considering Entry:
- *Notification Decision – Determine whether to enter the SDDT regime and submit notification to the PRA by 31 March 2026 if seeking to benefit from simplified rules
- *Policy Review – Conduct comprehensive review of PS20/25, related policy statements (PS18/25, PS19/25, PS8/25, PS14/25), and supporting methodologies (SoP5/25, SS4/25, amendments to SoP2/23)
- *Capital Calculation Transition – Prepare systems and processes to transition from current capital calculation methodologies to Basel 3
- Removal of CCR and CVA calculations for derivatives
Key Dates
31 March 2026 – Deadline for firms wishing to enter the SDDT regime to notify the PRA and benefit from the simplified framework at implementation. DEADLINE
1 January 2027 – Implementation date for the simplified capital regime for SDDTs; the Interim Capital Regime will no longer apply.
2026 (specific date TBD) – PRA to make final rules and policy covering the entire Basel 3.1 package once HM Treasury makes commencement regulations to revoke relevant CRR provisions.
2027 (specific date TBD) – PRA to implement restatement of CRR requirements (PS19/25).
Compliance Impact
Urgency Rating: HIGH
Bank
Policy statement 17/25
PS17/25 establishes the **Matching Adjustment Investment Accelerator (MAIA) framework**, enabling PRA-regulated insurers to regularize and expand their use of matching adjustment (MA) in calculating capital requirements for certain long-duration insurance liabilities. This framework is significant because it provides a structured pathway for firms to optimize capital efficiency while maintaining prudential safeguards through exposure limits, eligibility assessments, and breach remediation mechanisms.
What Changed
The MAIA framework introduces the following regulatory requirements:
*Permission and Eligibility Framework
Firms must obtain explicit MAIA permission** from the PRA to use the accelerator
Permission grants authority to regularize previously non-compliant MA assets and apply MA to new eligible assets within defined parameters
*Exposure Limits
Firms receive fixed monetary exposure limits** calibrated using the Best Estimate of Liabilities (BEL) of the MA portfolio, net of reinsurance, at the tim
What You Need To Do
- *Immediate (Q4 2025 - Q1 2026)
- *Assess eligibility for MAIA permission by reviewing current MA portfolio and prospective assets
- *Develop MAIA policy documenting asset eligibility criteria, governance structure, and risk management approach
- *Establish contingency plans for scenarios where MAIA assets become ineligible
- *Prepare MAIA permission application if pursuing the framework
Key Dates
27 October 2025 - PS17/25 final rules and policy material took effect; firms could begin applying for MAIA permission
31 December 2026 - Implementation deadline for changes to MALIR reporting template DEADLINE
18 weeks after financial year-end - Annual MAIA use report submission deadline (ongoing, annually) DEADLINE
2 months from breach identification - Deadline to rectify breaches to avoid MA benefit reduction DEADLINE
Compliance Impact
Urgency: HIGH
Insurance
Policy statement 21/25
PS21/25 implements reforms to PRA remuneration rules for banks, building societies, and PRA-designated investment firms, simplifying Material Risk Taker (MRT) identification, aligning deferral periods with international standards (4 years for non-SMF MRTs and 5 years for SMFs), and enhancing links to individual accountability under the Senior Managers Regime (SMR). These changes matter as they reduce regulatory burden, increase flexibility in bonus structures (e.g., marginal deferral rates and cash payments), and promote competitiveness while maintaining risk alignment, potentially reversing trends toward higher fixed pay.
#
What Changed
MRT Identification: Simplified quantitative threshold to the top 0.3% of earners (assessed against risk impact); qualitative criteria unchanged; raised proportionality threshold for disapplying rules from £44,000 variable pay to £660,000 total pay (with variable pay ≤33% of total); reintroduced exemption for MRTs serving <3 months.
Deferral Periods: 4-year minimum for non-SMF MRTs (previously varied); reduced to 5 years for SMFs (from 7 years); aligns with FCA and international practice.
Deferra
What You Need To Do
- Review and update MRT identification processes, applying simplified top 0
- Revise remuneration policies for deferral (4/5 years, marginal rates), upfront cash flexibility, and instrument expectations; update bonus award calculations
- Embed SMR-linked adjustments
- For dual-regulated firms
- Optional early adoption for specified changes on 2025/unvested awards; document governance for RemCo approvals and board policies
Key Dates
15 October 2025 Publication date; some changes (e.g., deferral periods, pro-rata vesting) may apply to ongoing 2025 performance year and unvested prior awards at firm discretion.
16 October 2025 Final rules and updated SS2/17 take effect; apply to performance years starting after this date (e.g., mandatory from 1 January 2026 for calendar-year firms).
November 2024 Preceding joint consultation (CP16/24/PRA, CP24/23/FCA) closed prior to PS.
Compliance Impact
Urgency: High – Mandatory from performance years post-16 October 2025 (e.g., 2026 for most), with immediate opt-in possible; impacts 2026 bonus cycles, requiring swift policy rewrites amid year-end planning. Matters due to simplified but ownership-heavy MRT processes, SMR-pay linkages raising accoun
BankAsset ManagerAll Firms
Policy statement 16/25
PS16/25 is the PRA's policy statement restating firm-facing organisational requirements from the MiFID Org Reg (e.g., outsourcing, record-keeping, risk management, compliance, internal audit, and governance) into the PRA Rulebook, with no material changes, to align with HMT's revocation of the EU regulation under FSMA 2023. This matters because it ensures continuity of prudential oversight for PRA-authorised firms post-revocation, preventing enforcement gaps in systems and controls while adapting provisions (e.g., supervisory function) to UK governance structures.
#
What Changed
Restatement of requirements: Provisions from MiFID Org Reg Articles on outsourcing, record-keeping, control procedures, risk management, compliance, internal audit, and governance are transferred verbatim or with minor clarifications into PRA Rulebook parts (e.g., Risk Control).
Supervisory function adjustment: Following consultation feedback, PRA retained Article 25 provisions but substituted "governing body" for "supervisory function" to fit UK firm structures, preserving board-level oversight
What You Need To Do
- Review and map existing MiFID Org Reg compliance processes against restated PRA Rulebook provisions (e
- Confirm governing body oversight aligns with adapted Article 25 requirements; document any adjustments for UK structures
- Update internal references in algorithmic trading governance documents to new rule 2
- Conduct gap analysis and training on minor clarifications; prepare for dual FCA/PRA alignment if applicable
- Monitor HMT commencement order; if delayed, reassess implementation plans
Key Dates
9 October 2025 - PRA publishes PS16/25 with final rules and feedback to CP9/25 consultation.
23 October 2025 - New PRA rules and technical standards come into force, coinciding with HMT's anticipated revocation of MiFID Org Reg via commencement order (FCA rules align on same date).
Prior to 23 October 2025 - HMT expected to lay second Statutory Instrument revoking remaining MiFID Org Reg provisions; PRA may delay/revoke rules if not made.
Compliance Impact
Urgency: High – Firms must act promptly as rules take effect on 23 October 2025 (past deadline as of current date), with no transition period; non-compliance risks enforcement gaps in core systems/controls post-revocation. Impact is low for substance (restatement only) but requires documentation upd
BankBroker DealerAll Firms
Policy statement 15/25
PS15/25 introduces **new liquidity risk reporting requirements for major UK insurance firms**, closing data gaps identified during the March 2020 "dash for cash" and September 2022 LDI crisis. The policy mandates four new reporting templates for firms with significant derivatives or securities lending exposure, with implementation deferred to **30 September 2026** to allow adequate preparation time.
What Changed
The PRA's final policy establishes the following regulatory framework:
*New Reporting Templates**
Four new liquidity reporting templates have been introduced to capture previously unavailable data:
Annual committed facilities template
Monthly cash-flow mismatch template (short form)
Monthly cash-flow mismatch template for ring-fenced funds, matching adjustment portfolios, and remaining parts
Additional supervisory reporting requirements
*Scope and Thresholds
Firms are subject to liquidity repo
What You Need To Do
- *Immediate Actions (by Q2 2026)
- *Threshold Assessment
- *RFF Mapping
- *System Readiness
- *Data Governance
Key Dates
30 September 2025 - PRA published PS15/25 (policy statement)
31 December 2025 - Original implementation deadline (now superseded) DEADLINE
30 September 2026 - **Final implementation date for all liquidity reporting requirements**
First reporting reference date after 30 September 2026 - Firms meeting threshold conditions must commence reporting DEADLINE
Three consecutive annual reporting reference dates - Threshold for ceasing reporting once firms fall below thresholds
Compliance Impact
Urgency: HIGH
Insurance
Asset management The AMF has postponed the effective date of the authorisation withdrawal of the asset management company Nestadio Capital
The Autorité des Marchés Financiers (AMF) postponed the effective date of the authorization withdrawal for Nestadio Capital, a portfolio asset management company, to allow time for fund transfers or liquidation following repeated non-compliance with authorization terms. This matters for compliance professionals as it illustrates AMF's enforcement approach to regulatory breaches in asset management, emphasizing orderly wind-downs to protect investors while signaling risks of judicial intervention if issues persist. The case culminated in judicial liquidation by 2022, highlighting long-term consequences for non-compliant firms.
#
What Changed
Initial authorization withdrawal decided on 17 December 2019 due to Nestadio Capital's failure to comply with authorization terms, including capital requirements, with original effective date at the latest 1 July 2020 (or upon fund transfer/liquidation).
Multiple postponements: 9 June 2020 and 8 December 2020 extended to 30 June 2021; 8 June 2021 further extended to 31 December 2021 to facilitate fund sales and liquidation.
7 December 2021 postponement tied withdrawal effect to full fund liquida
What You Need To Do
- For Nestadio Capital (historical)
- For investors
- For industry peers
- AMF referrals to courts underscore need for firms to self-report issues early to avoid escalation
Key Dates
17 December 2019 - AMF Board decides authorization withdrawal.
1 July 2020 - Original latest effective date for withdrawal (or fund transfer/liquidation).
9 June 2020 & **8 December 2020** - Postponements to **30 June 2021**.
8 June 2021 - Postponement to **31 December 2021** for fund sales/liquidation.
4 October 2021 - Conseil d'Etat rejects Nestadio's appeal.
Compliance Impact
Urgency: low - This is a resolved 2019-2022 enforcement case with no ongoing deadlines or new rules as of 2026; Nestadio is in judicial liquidation. It matters as a precedent for AMF's phased withdrawal process, protecting investors via extensions and liquidators, but warns asset managers of severe
Asset Manager